United States: CFIUS Issues Its First-ever Enforcement and Penalty Guidelines

The Committee on Foreign Investment in the United States (CFIUS) issued its first-ever Enforcement and Penalty Guidelines for entities that violate mitigation agreements with CFIUS or otherwise run afoul of Section 721 of the Defense Production Act of 1950 and the regulations promulgated thereunder.

United States: OFAC Issues New Sanctions Compliance Guidance for Instant Payment Systems

On September 30, 2022, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury published its "Sanctions Compliance Guidance for Instant Payment Systems" designed to help financial institutions allocate their compliance resources consistent with their sanctions risks.

United States: CHIPS Act Guardrails

Nineteen months after Congress first authorized the CHIPS for America Fund, and following months of unproductive conference committee negotiations, the Senate has moved Congress closer to funding a slimmed-down—albeit still massive—program to aid the expansion of domestic semiconductor manufacturing.

USA: Detention Order on Cotton and Cotton Products Originating From the Xinjiang Production and Construction Corps

The Arnold & Porter team discusses implications of the recently announced Withhold Release Order by the U.S. Customs and Border Protection Agency against shipments containing cotton and cotton products into the U.S. from the major Chinese entity Xinjiang Production and Construction Corps (XPCC).